There is evidence that the company\u2019s Chairman and CEO publicly endorses the company\u2019s 2018 Sustainability Report, which includes a commitment to anti-bribery and corruption. However, the company scores \u20181\u2019 because this statement does not directly include a commitment to anti-bribery and corruption. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an anti-bribery and corruption policy which applies to all groups as specified in (a) and (b) in the question. This policy explicitly prohibits bribery and payments to public officials. <\/p>\n
However, the company receives a score of \u20181\u2019 because this policy does not explicitly prohibit facilitation payments.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s board is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance. There is evidence that the board has the authority to require that changes are made. The company also has a managerial-level committee, the Ethical Principles Committee, which is responsible for the design and measurement of the programme.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
Based on publicly available information, there is no evidence that a designated senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is publicly available evidence that the company\u2019s Internal Audit Department systematically reviews bribery and corruption risks. The company also states that executives are responsible for evaluating and implementing controls in response to potential risks. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its entire anti-bribery and corruption programme. There is evidence that the company has an enterprise risk management process where the results are reviewed by the board on an annual basis; however, the company does not explicitly state that an assessment of bribery and corruption risk forms part of this process. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review by its Internal Audit Department. The company states that results of these reviews are presented to the board, which is responsible for ensuring that required changes are made.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is unclear how frequently audits are conducted. There is no clear evidence that the company\u2019s entire programme is audited at least every two years to ensure that it is consistent with high standards of best practice and the business risks facing the company. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases. There is evidence to suggest that a central body, the Ethical Principles Committee, receives summary information on investigations. It meets on at a quarterly basis and reports investigation findings to the board on a bi-annual basis.<\/p>\n
However, the company does not publish information on the whole investigative process from receipt to final outcome. There is no clear evidence that investigations are handled by an independent team or report to an independent board member. The company also does not publicly commit to inform whistleblowers of the outcome of investigations. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company takes steps to ensure the quality of its internal investigations through ensuring that staff are properly trained or providing a mechanism to report concerns about the investigative procedure. <\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption from investigations to the CEO and to the board. However, there is no clear evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of its anti-bribery and corruption policy to its employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this also includes an explanation of the whistleblowing options available to employees. It is also not clear how frequently training is provided, and whether it is provided across all divisions, all countries and regions of operation, or in all appropriate languages.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company makes a specific commitment to support and protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy of non-retaliation against all employees who report bribery and corruption incidents. There is some evidence to suggest that this commitment extends to third parties engaged by the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides multiple whistleblowing channels for its employees, which allow for anonymous reporting. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company offers a channel operated by an independent third party to allow external reporting, or is there clear evidence that the company also offers advice channels. Additionally, the company does not explicitly state that its channels are available to all employees in any country of operation, or in multiple languages, or to employees of third parties, suppliers or joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a conflicts of interest policy, which applies to all employees and board members, and covers actual, potential and perceived conflicts of interest. This policy covers conflicts relating to personal relationships, financial interests and outside employment.<\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not address conflicts of interest associated with government relationships.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is some evidence to indicate that the company\u2019s Corporate Governance Committee has a role in the oversight and management of conflicts of interest. However, the company receives a score of \u20181\u2019 because it does not provide sufficient information on its specific procedures and mechanisms for identifying, declaring and managing conflicts of interest. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it prohibits corporate political contributions, whether made directly or indirectly. There is evidence that this applies to all employees of the company including directors, third parties, suppliers and joint venture partners. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
There is evidence that the company prohibits corporate political contributions so the company is exempted from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has procedures covering both charitable donations and sponsorships. There is evidence that these include measures to ensure that donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations and a requirement for the board to sign-off on donations. In addition, the company publishes some details of donations made on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not disclose full details of charitable donations made, such as the entity which made the donation or details of recipient organisations. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. There is some evidence to suggest that the company records gifts in a register.<\/p>\n
However, the company receives a score of \u20181\u2019 because the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses, nor does it specifically address the risks associated with gifts and hospitality given to\/received from public officials. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships, and that this department is the main body responsible for oversight of the company\u2019s supplier base. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company assures itself assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence on all suppliers during the selection and appointment phase. The company states that it will not engage with any suppliers or subcontractors that have been involved in corrupt activity, though it is not clear whether this stems from the results of due diligence. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that due diligence includes checks on ultimate beneficial ownership, nor is there evidence to suggest that highest risk suppliers are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or in response to a change in the business relationship.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires its suppliers to follow similar principles to those outlined in its Ethical Principles document, which prohibits bribery.<\/p>\n
However, the company does not clearly state that all suppliers must prohibit facilitation payments, and have policies that cover conflicts of interest, gifts and hospitality, and whistleblowing. There is also no evidence to suggest that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy on agents which addresses the corruption risks associated with their use. The company states that it has a policy on the \u2018Appointment and Management of Foreign Agents\u2019, however this document does not appear to be publicly available so it is unclear whether the company recognises the corruption risks associated with agents or has specific controls in place to mitigate these risks. In addition, there is no evidence that the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is insufficient evidence to indicate whether the company has procedures in place to conduct anti-bribery and corruption due diligence on its agents and intermediaries. The company states that it has a policy on the \u2018Appointment and Management of Foreign Agents\u2019, however this document does not appear to be publicly available so it is unclear whether due diligence forms a part of the selection and appointment process. Furthermore, the company states that it will not engage with firms found to have been involved in corrupt activity, but it is not clear that this stems from a due diligence process. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. There is some evidence that the company\u2019s anti-bribery and corruption policy applies to companies providing consultancy services to the company, but it is not clear that the policy applies to agents and intermediaries acting on the company\u2019s behalf.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company addresses incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, incidents or the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures to conduct due diligence on business partners \u2013 which is understood to include joint venture partners \u2013 during the selection and appointment phase. The company states that it will not engage with any partners that have been involved in corrupt activity, though it is not clear whether this stems from the results of due diligence. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the selection process includes checks on ultimate beneficial ownership, nor is there evidence to suggest that highest risk partners \u2013 such as state-owned enterprises \u2013 are subject to enhanced due diligence. There is also no evidence that due diligence is repeated at least every two years or in response to a change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to joint ventures in which the company holds more than 49% of shares or voting rights. The company also indicates that it takes steps to ensure compliance with the policy in joint ventures where it holds less than 49% of shares or voting rights by conducting certain checks on the entity.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the company includes anti-bribery and corruption clauses in its contracts with joint venture partners to detect, control and prevent breaches. The nature of the checks that the company conducts to ensure compliance in minority-owned joint ventures is also unclear. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company commits to taking an active role in preventing bribery and corruption in all its joint ventures. There is evidence that the company\u2019s policy applies to majority-owned joint ventures and that it takes steps to ensure compliance in minority-owned joint ventures, but the publicly available details of the steps taken to ensure this is not sufficiently detailed to receive a score of \u20181\u2019. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company addresses the corruption risks associated with offset contracting or that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"1","comments":"
There is evidence that the company publishes some information about the beneficiaries of its offset projects. The company indicates that its main offset or industrial participation commitments stem from the Presidency of Defense Industries in Turkey; the company provides some other information about its industrial cooperation projects associated with the Electronic Warfare Business but it is not clear whether these represent direct or indirect offsets. <\/p>\n
The company receives a score of \u20181\u2019 because it does not provide full details about the beneficiaries of its indirect offsets in a clear way; for example, the company does not list the name of the company or organisation receiving the investment and the country in which the recipient entity is based. The information provided is briefly mentioned in the Annual Report, so there is also no evidence that this represents a complete list of all the company\u2019s indirect offset projects.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company acknowledges the corruption risks of operating in different markets, nor that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
The company publishes details of its fully consolidated subsidiaries and non-fully consolidated holdings, including associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation, while also providing descriptions to indicate the country of operation. There is evidence that this list is current and updated on at least an annual basis. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company discloses information about its beneficial ownership. The company is partially listed on the Istanbul Stock Exchange and discloses all shareholders on its website with a stake of 25% or higher. There is evidence that the company\u2019s major shareholder is the Turkish Armed Forces Foundation, which is associated with the Turkish government. The company also discloses its shareholders in a publicly accessible central register in Turkey. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
The company discloses that the Turkish government and several Turkish companies account for over 90% of total orders, and that non-defence orders account for 6% of total orders. Based on this evidence, there is evidence that public and private customers in Turkey represent the main customers for over 80% of the company\u2019s defence sales. There is evidence that this data is correct and up to date up to the most recently reported financial year.<\/p>\n"},{"question":111,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information about its shareholder voting rights, broken down by the percentage allocated to each shareholder. The company publishes the beneficial ownership and voting rights of shareholders with at least 25% of voting rights.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
The company publishes some information about its commercial and public policy objectives and there is evidence to suggest that these are updated on an annual basis. Although these objectives are relatively broad and high-level, they provide sufficient insight into the company\u2019s aims and objectives to receive a score of \u20182\u2019. <\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes clear information about the nomination process, appointment and composition of its board and provides details of its board members. The company discloses the process by which directors are nominated by shareholders. For each board member, the company discloses whether that person has a connection to the company or the state or is an independent director.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
There is publicly available evidence that the company\u2019s Audit Committee is composed entirely of independent directors. <\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a system in place to manage asset transactions, with responsibility held at board level. <\/p>\n
However, there is no clear public evidence that asset transactions are subject to scrutiny by an audit body. It is unclear whether all transactions are documented, including those between the company and government departments or the military. In addition, the financial results from asset acquisitions are not published in the company\u2019s reports.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/439","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=439"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=439"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}